DATA PROTECTION POLICY & PRIVACY NOTICE

Section One – Data Protection Policy

MOVAS LTD provide language translation services by matching their professional translators to projects in a bespoke service tailored to requirements.

For any queries regarding the content of this Policy Document and Privacy Notice, or any requests to access data held, please contact on info@easytranslated.com

UNDERSTANDING OUR OBLIGATIONS

MOVAS LTD have assessed and documented all processing activities conducted regularly, those exposing data to a high-risk and any sensitive personal data. These activities have been justified using the Legal Bases and Special Conditions provided in the Regulations and written into a Privacy Notice.

DATA SUBJECT ACCESS RIGHTS

Individuals have the right to request details of any personal information that MOVAS LTD may hold on you, and you have increased rights regarding our use of that information, including;

• The right to request rectification of information that is inaccurate or out of date
• The right to erasure of your information (also known as “the right to be forgotten”)
• The right to restrict the way in which we are dealing with and using your information
• The right to request that your information be provided to you in a format that is secure and suitable for re-use (also known as “the right to portability”)

MOVAS LTD acknowledges that any person may ask if any information is held containing their personal data. MOVAS LTD will respond to written requests as soon as possible, not taking any longer than 30 days to provide copies of any data held. The company shall correct any errors if requested, and agrees to delete records where this is permitted under the Legal Basis.

REVIEW OF DATA PROTECTION POLICY AND PRIVACY NOTICE

Data Protection is a standing agenda item at the MOVAS LTD Management Review Meeting; this includes a review of the Data Protection Impact Assessment and Privacy Notice for relevance and accuracy.  The documents, and this policy document, shall be reviewed in full at least annually.

SECURITY DETAILS

Every effort is made to manage the personal information held by MOVAS LTD in a responsible and secure manner.  To this end, all networked equipment is encrypted and password protected, stored on encrypted Cloud servers. This is backed up by our IT provider, Resonate Cloud Services.

Cloud based Google Drive used for Project File Management enables restricted access to assigned Project Managers only.

BREACH RESPONSE

In the event of a breach, such as a break-in, loss or theft of a laptop or phone, all staff and current clients will be made aware.  If there is a serious risk of personal data being misused, then all contacts will be informed; within one day of the breach being discovered, MOVAS LTD will then take guidance on further action, with further notice to the client.

Section Two – Privacy Notice

All documents remain the property and intellectual property of the client.

PROCESSING ACTIVITY STATEMENTS

ACTIVITY

Purpose/justification – Legal Basis / Special Condition

TRANSLATION SERVICES

FILE TRANSFER

Receipt and return of translation file documents, preferred method is using Cloud based Google Drive, though some clients prefer an email exchange and this is used where requested – Contract

DOCUMENT REVIEW

Review and assessment of translation required to appoint suitable linguist – Contract

FILE ENGINEERING

Where required, translation documents are converted to an alternative format before sending to Linguist – Contract

INSIGHTLY CRM SOFTWARE

ORDER HISTORY

Retention of previous translation services to optimise future customer service – Legitimate Interests

CUSTOMER RECORD

Retention of basic contact details for the provision of services – Contract

GENERAL CONTACTS

DATABASE OF CONTACT INFORMATION FOR BUSINESSES

Business contacts from networking and referrals for the promotion of MOVAS LTD – Legitimate Interests

WEBSITE

Cookies are text files generated by the website and stored on the user’s computer partly for marketing purposes and Lead Generation – Legitimate Interests

STAFF

ABSENCE MONITORING AND APPRAISALS

To monitor performance, sickness and holiday absences – Legitimate Interests

EMPLOYMENT RECORDS

Retention of application form and contract, copies of identification and qualifications where applicable – Legal Obligation / Special Condition B Legal Compliance

PREFERRED LINGUISTS*

Retention of copies of identification, CV and qualifications, contact information and country of residence where applicable – Legal Obligation / Special Condition B Legal Compliance

SHARED DATA / DATA CONTROL

Data will only be shared with the supplier(s) directly involved with the project (i.e. translators / linguists). All suppliers are bound to full confidentiality as stipulated in the terms of our Supplier Agreement.

The ‘Data Controller’ is the customer. MOVAS LTD acts as the data processor and does not claim control over the data supplied by customers. Customers may reserve the right to have MOVAS LTD delete or return any data as they wish.

*For some translation projects, the client requests the identity of the Linguist, this is shared via the secure Cloud-based system.